Submitted on June 4 to Larimer County Commissioners and Staff:

June 4, 2021

Dear Commissioners,

The Larimer Alliance appreciates the improvements in the proposed revisions to the County’s Oil & Gas regulations.

We would like to offer these suggestions to enhance section 11.3.3 (Air Quality).

• Adding the section: Assessments. Studies, and Plans by Outside Experts. Independent experts, engineers or consultants referenced in this section will be retained by the Applicant and be subject to approval by Larimer County.
  • Air Quality
    • Existing emissions – An inventory of methane, VOC’s, NOx, CO₂, and particulate emissions must be conducted by an independent expert chosen and approved by the County and paid for by the applicant for all oil and gas facilities and operations in Larimer County owned or operated by the Applicant for the calendar year prior to registration or renewal. Operators must submit all Air Pollution Emission Notices for hazardous air pollutants submitted to the Air Pollution Control Division to the independent expert for review.
    • Air Quality Modeling – A modeling study must be conducted by an independent expert that considers all relevant environmental and atmospheric conditions, and:
      • Assesses the existing air quality at the proposed site;
      • Predicts the anticipated emissions (including hazardous air pollutants, methane, VOCs, NOx CO₂, and particulate emissions) from the proposed oil and gas facilities and operations, assuming use of and identifying all emissions control equipment and processes intended for use at the oil and gas facilities; and
      • Models the impacts on air quality from the proposed oil and gas facilities and operations over their lifetime, until final reclamation obligations are completed to the County’s satisfaction, including the compounding effects of climate change on ozone and particulate pollution in the county and taking into account and identifying all relevant factors including natural conditions and other air quality impacts from any existing or foreseeable source.

• • Adding these additional items:
  • Compliance with the National Ambient Air Quality Standards. Oil and gas facilities and operations will not compromise the attainment of ozone standards of the Denver Metro/North Front Range ozone nonattainment area as established by the US Environmental Protection Agency (EPA). Oil and gas facilities and operations will not contribute particulate matter to the air in a manner that fails to protect public health.
  •  To protect air quality and public health, emissions control measures may be required, including, but not limited to, one or more of the following:
    • Compliance with the current, most protective air quality regulations and health-based standards, which may include regulations and standards set by the EPA, CDPHE, COGCC, Centers for Disease Control, or other relevant authorities.
  • Operators will maintain a daily log documenting reduced emission completions, available for inspection upon request.
  • Operator participation in the Natural Gas STAR Program or other voluntary programs to promote innovation in pollution control.
  • Tier 4 fracturing pumps and either electric or Tier 4 diesel engines.  These requirements will result in significant reductions of emissions and noise.
  • J. Air quality requirements for both new and existing facilities – Add the following language to the County’s 5/12/21 draft:
    • Within thirty days following the conclusion of each Air Quality Action Advisory Day, operators shall submit a report to the County that details which measures it implemented during that Air Quality Action Advisory Day.

We would urge that any documents (emissions inventories, modeling studies, reports, and daily logs of reduced emissions) produced for or by the operator, along with the documentation required and produced by the Operators to alleviate the increased air quality dangers associated with Air Quality Action Advisory Days be considered public so they can be posted on the County’s website or disseminated to the public upon request.

Thank you for improving the Air Quality section.   We appreciate the magnitude of work that has been put in thus far.

Sincerely,

Tim Gosar & Gayla Martinez

for the Larimer Alliance for Health, Safety & the Environment.

www.larimeralliance.org